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ASCs Must Begin Using Safe Surgery Checklists January 1, 2012

Safe Surgery Checklists – New Requirement For Ambulatory Surgery CentersASC Safe Surgery Checklist Requirement

ASCs should mark their calendars for January 1, 2012 which is the date that CMS requires the use of Safe Surgery Checklists to begin.  Beginning in July of 2013, ambulatory surgery centers will be required to certify that they used a safe surgery checklist throughout calendar year 2012.  The safe surgery checklist covers three key preoperative stages.  The three stages include (1) the period prior to anesthesia and sedation being administered, (2) the period prior to incision, and (3) the period prior to the patient leaving the operating or procedure room.

The certification will need to be made by ASCs within a 45 day window period between July 1, 2013 and August 15, 2013.  CMS will be providing a web-based mechanism that providers can use to certify their compliance with the safe surgery list requirement.

CMS does not provide a required form of safe surgery checklist but has rather left this to the discretion of the ASC.  Comments to the regulations point to external sources that have developed safe surgery checklists including the World Health Organization and the World Federation of Societies of Anesthesiologists.  The WHO safe surgery checklist can be found at the following link.  WHO Safe Surgery Checklist

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John H. Fisher

Health Care Counsel
Ruder Ware, L.L.S.C.
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